ML17159A167
| ML17159A167 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/05/1998 |
| From: | Stolz J NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NOED-98-6-002, NOED-98-6-2, TAC-MA0752, TAC-MA0753, TAC-MA752, TAC-MA753, NUDOCS 9803090321 | |
| Download: ML17159A167 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 5, 1998 Mr. Robert G. Byram Senior Vice President-Generation and Chief Nuclear Officer Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED 98-6-002) FOR PENNSYLVANIAPOWER AND LIGHTCOMPANY (PP&L), SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNITS 1 AND2 (TAC NOS. MA0752 AND MA0753)
Dear Mr; Byram:
By letter dated February 3, 1998, you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) Surveillance Requirement 4.6.1.2, which requires that the plant enter TS 4.0.3 ifthere is a failure to perform a Surveillance Requirement within the allowed surveillance interval. You indicated that to perform the surveillance on 33 instrument lines (that you failed to test) willtake 2 weeks.
TS 4.0.3 allows the surveillance to be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit completion of the surveillance.
At the expiration of this time, the action statement of Limiting Condition for Operation (LCO) 3.6.1.1 will apply, which requires that within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, restore primary containment integrity or the unit must be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Your letter also requested that a NOED be issued and be effective for the time period from February 4, 1997, at 12:05 a.m. EDT until a TS change (you submitted marked-up pages by letter dated February 3, 1998) can be approved.
This proposed TS change, when issued, willbe in effect until the restarts from the SSES, Unit 1 April 1998 refueling outage and the SSES, Unit 2 April 1999 refueling outage or in effect until the restart from an earlier forced shutdown of either unit at which the time testing willbe performed.
Your letter also documents information previously discussed with the NRC staff in a telephone conversation on February 3, 1998, that started at approximately 4:30 p.m. EDT, in which you stated that on February 4, 1998, at 12:05 a.m. EDT, the'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided by TS 4.0.3 will l
expire.
In preparations for leak rate testing in the upcoming SSES, Unit 1 refueling outage, PP8L discovered a number of instrument line penetrations on each unit that have been designated as "extensions of containment," but a portion of each instrument line (3/8" dia.), including the instrument, was isolated during past Appendix J, Type A tests.
Based on this conclusion, PP&L, on February 3, 1998, at 12:05 a.m., entered TS 4.0.3 on SSES, Units 1 and 2, due to the identification of a missed surveillance requirement.
The root cause of the missed surveillance is still under investigation.
You noted that many of the penetrations combine several instruments with active functions on the same instrument line and present a risk for backfeeding pressure to'other instruments.
Ifthe tests were done while the plant was on-line, the backfeeding pressure could lead to an inadvertent plant trip and an undesirable transient.
You committed to perform monthly calibrations of each of the affected instruments associated with penetrations X-32A and X-3B to confirm the absence of unacceptable leakage until completion of the additional Appendix J tests described in your February 3, 1998 letter.
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R. Byram You also agreed to provide with your license amendment submittal information regarding:
the root cause; revised dose calculations associated with additional postulated leakage before the tests are completed; the acceptance criteria you willuse during on-line testing discussed in Item 7 in your February 3, 1998 letter; and the acceptance criteria that you will use during off-line testing.
The staff has concluded that your request satisfies the criteria for issuance of a NOED as provided in the "NRC Inspection Manual Part 9900 10 CFR Part 2, Appendix C Enforcement Discretion." Specifically, the exercise of enforcement discretion is intended to avoid undesirable transients as a result of forcing compliance with the license condition and, thus, minimize potential consequences of operational risks.
On the basis of the staffs evaluation of your request described above, the staff has further concluded that the exercise of enforcement discretion is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse impact on public health and safety.
It is our intention to exercise discretion, not to enforce compliance with the LCO associated with TS 4.0.3 for the period from 12:05 a.m. EDT, February 4, 1998, until issuance of a license amendment.
This letter documents our telephone conversation on February 3, 1998, during which we verbally approved your request for enforcement discretion.
However, as stated in NUREG-1600, "General Policy and Procedures for Enforcement Actions,"
enforcement action willnormally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance forwhich this discretion was granted.
Docket Nos. 50-387/50-388 cc: See next page Sincerely, J. Williams /s/ for John F. Stolz, Director Project Directorate l-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation DISTRIBUTION Docket File PUBLIC PDI-2 Reading HThompson SCollins/FMiraglia BBoger BSheron GHolahan JZwolin ski JStolz VNerses MO'Brien E-Mail NOED E-Mail NRCWEB CAnderson, RGN-I JCrlenjak, RGN-I OGC WBeckner
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/698 OFFICIALRECORD COPY DOCUMENT NAME: SU0752.NOD
R. Byram You also agreed to provide with your license amendment submittal information regarding:
the root cause; revised dose calculations associated with additional postulated leakage before the tests are completed; the acceptance criteria you willuse during on-line testing discussed in Item 7 in your February 3, 1998 letter, and the acceptance criteria that you willuse during off-line testing.
The staff has concluded that your request satisfies the criteria for issuance of a NOED as provided in the "NRC Inspection Manual Part 9900 10 CFR Part 2, Appendix C Enforcement Discretion." Specifically, the exercise of enforcement discretion is intended to avoid undesirable transients as a result of forcing compliance with the license condition and, thus, minimize potential consequences of operational risks.
On the basis of the staff's evaluation of your request described above, the staff has further concluded that the exercise of enforcement discretion is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse impact on public health and safety.
It is our intention to exercise discretion, not to enforce compliance with the LCO associated with TS 4.0.3 for the period from 12:05 a.m. EDT, February 4, 1998, until issuance of a license amendment.
This letter documents our telephone conversation on February 3, 1998, during which we verbally approved your request for enforcement discretion.
However, as stated in NUREG-1600, "General Policy and Procedures for Enforcement Actions,"
enforcement action willnormally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this discretion was granted.I Sincerely, fOM John F. Stolz, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/50-388 cc: See next page
Mr. Robert G. Byram Pennsylvania Power & Light Company Susquehanna Steam Electric Station, Units 1 &2 Jay Silberg, Esq.
Shaw, Pittman, Potts &Trowbridge 2300 N Street N.W.
Washington, D.C. 20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Licensing Group Supervisor Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania ISI01 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 35 Berwick, Pennsylvania 18603-0035 Director-Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. O. Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, lnc.
212 Locust Street P.O. Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 General Manager Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1, Box 1797 Berwick, Pennsylvania 18603 George T. Jones Vice President-Nuclear Operations Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Chairman Board of Supervisors 738 East Third Street Berwick, PA 18603
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